If the checks are not drawn on or payable at a bank in the United States (as the term "bank" is expanded in the Regulation), they are not subject to Regulation CC at all.
Be careful. If the check is drawn on a non-US bank but payable at one of their U.S. offices, it's a check and will be local or nonlocal depending on the location of that office relative to your receiving branch.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8